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The item Die neuen Regelungen zu hybriden Gestaltungen im Überblick = An overview of the new provisions on hybrid mismatches represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.

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After the implementation of the Anti-Tax Avoidance Directive (ATAD), especially its CFC regime, in the Annual Tax Act 2018, now the next step is due in Austria. The provisions on hybrid mismatches, introduced in 2017 via ATAD II (Directive Amending ATAD I), must be implemented into national law by the beginning of 2020. These provisions are highly complex and require particular legislative caution. With the draft of the Tax Reform Act I 2019/20, the Austrian Ministry of Finance tackles this delicate task. In this article, the author provides a first overview of the new provisions on hybrid mismatches

After the implementation of the Anti-Tax Avoidance Directive (ATAD), especially its CFC regime, in the Annual Tax Act 2018, now the next step is due in Austria. The provisions on hybrid mismatches, introduced in 2017 via ATAD II (Directive Amending ATAD I), must be implemented into national law by the beginning of 2020. These provisions are highly complex and require particular legislative caution. With the draft of the Tax Reform Act I 2019/20, the Austrian Ministry of Finance tackles this delicate task. In this article, the author provides a first overview of the new provisions on hybrid mismatches